If your institution is subject to HMDA, the first thing you have to do when you receive a loan application is determine if it’s HMDA reportable. So, the first question to ask yourself is will the loan be dwelling-secured? If so, you can move on to the next question of whether the request is for a HMDA-reportable purpose [Purchase, Refinance, Improvement, or Other (aka Consumer-Purpose Home Equity)]. If so, it’s subject to HMDA, which means there are some things you need to request at the time of application to later report on your HMDA-LAR. But, you first need to understand what is and what is not considered a dwelling under the HMDA rules. There are some exceptions and, quite honestly, they don’t always make sense. One exclusion is for ag properties/farms.
David explains more in the video.
Published
2024/05/20